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Corey Heaps <br />CAM - Colorado, LLC <br />November 30,20 10 <br />Page 24 <br />please provide the Division with a justification of why total metals analyses are valid and <br />please describe how the analytical results will be used in conjunction with the CDPHE <br />receiving stream standards. <br />97. In Table 2 — Surface Water, on page 2.05 -57 of Section 2.05.6(3)(b)(iv), CAM lists that <br />chromium (Cr) will be analyzed. CDPHE receiving standards require the analysis of both <br />chromium III (Cr +3 ) and chromium VI (Cr 6 ). Please include both chromium III (Cr +3 ) and <br />chromium VI (Cr + ) in Table 2. <br />98. Please add total hardness, flow, lab pH and lab conductivity to the list of surface water <br />sampling parameters in Table 2 on permit text page 2.05 -57 of Section 2.05.6(3)(b)(iv). <br />99. Please add measurement units to each of the constituents listed in Table 2 on permit text <br />page 2.05 -57 of Section 2.05.6(3)(b)(iv). <br />Rule 2.06.8(3) Alluvial Valley Floor Determination <br />100. CAM presented an Alluvial Valley Floor (AVF) report prepared by ERO Resources <br />Corporation. This report is found in Volume 1 Tab 14 of the permit application package. <br />On page 1, CAM describes that the AVF investigation of the site consisted of a site visit <br />and a review of existing geologic maps, existing air photography, ground water quality data <br />from existing monitoring wells, geologic logs of monitoring wells, and results of a Toxicity <br />Characteristic Leaching Procedure (TCLP) analysis of the coal to be loaded at the site. <br />According to 2.06.8(3)(b), field investigations shall include sufficiently detailed geologic, <br />hydrologic, land use, soils, and vegetation studies. Please amend the initial investigation <br />to include information on soils, vegetation and land use. Specifically, refer to 2.06.8(3)(b) <br />for information to provide. <br />101. According to 2.06.8(3)(b)(i), in order for the Division to determine if the proposed site will <br />affect an AVF, the following needs to be submitted: mapping of unconsolidated streamlaid <br />deposits holding streams including but not limited to, geologic maps of unconsolidated <br />deposits, maps of streams, delineation of surface waters and directions of shallow ground <br />water flows through and into unconsolidated deposits, topography showing local and <br />regional terrace levels, and topography of terraces, flood plains and channels showing <br />surface drainage patterns. Please provide a map with this information. <br />102. In the narrative regarding groundwater on page 3, please provide language to meet the <br />following questions. Does it meet the geomorphic criteria? Are portions of the site flood <br />irrigable? Please include a discussion and map on the capability of this area to be flood <br />irrigated as required by Rule 2.06.8(3)(b)(i). <br />103. The first paragraph on page 5 states that the proposed load out property clearly overlies <br />alluvium of the historic Colorado River. CAM then questions whether or not this layer <br />